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The Illinois Administrator has filed a complaint against the former chief of staff of former Governor Rod Blagojevich.

The charges are based on the attorney's guilty plea to wire fraud:

In his plea agreement, Respondent admits that from October 2008 through December 9, 2008, he participated with Blagojevich in a scheme to deprive the people of the State of Illinois of the intangible right to honest services. (Exh. 2, p.2) Blagojevich, Respondent and others sought to obtain financial benefits for Blagojevich and his wife in return for the exercise of Blagojevich's duty under Illinois law to appoint a United States Senator to fill the vacancy created by the election of President Obama. (Id., pp. 2-3) As detailed in the plea agreement, Respondent assisted Blagojevich's efforts by suggesting means by which Blagojevich could secure personal benefits for himself. (Id., pp. 2-3)

Shortly before and immediately after the November 4, 2008 election of President Obama, Blagojevich's discussions with Respondent about his appointment of a replacement Senator became more frequent and more detailed. (Exh. 2, p.4) Respondent knew of Blagojevich's discussions with a small group of internal and external advisors about the issue. (Id.) Blagojevich made it clear to Respondent that Blagojevich was not focused on what was in the best interest of the People of the State of Illinois, but instead was focused on what Blagojevich could personally obtain for himself in exchange for the Senate appointment. (Id.)

Around the time of the November 4, 2008 election, Respondent learned that an individual identified as Senate Candidate B was interested in the Senate seat. (Id.) Blagojevich discussed with Respondent that he wanted to use Senate Candidate B's interest in the Senate seat as a way to get something for himself from President-elect Obama. (Id.) Initially Blagojevich wanted to be appointed Secretary of Health and Human Services ("HHS"). On or about November 6, 2008, Blagojevich met with an individual identified as Service Employees International Union ("SEIU") Official A who had been presented to Blagojevich and Respondent as working on behalf of President-elect Obama to fill the Senate seat. (Id.) Prior to the meeting, Respondent helped Blagojevich strategize as to how to ask SEIU Official A for the HHS position in exchange for making Senate Candidate B the Senator. (Id.) After the meeting, Blagojevich told Respondent that he had asked SEIU Official A for the HHS position in exchange for the appointment of Senate Candidate B as Senator. (Id., p.5)

During the discussions with Respondent, Blagojevich expressed interest in obtaining an ambassadorship from President-elect Obama in exchange for making Senate Candidate B the Senator. (Id.) On November 5, 2008, Blagojevich told Respondent and Deputy Governor A to research the ambassadorship options for him as well as to research private foundations where Blagojevich might be able to get a high-paying position in exchange for making Senate Candidate B the Senator. (Exh. 2, p. 5) Respondent explained to Blagojevich the reasons Respondent believed that the private foundation option was preferable to the ambassadorship. (Id., pp. 5-6)

Respondent admits in the plea agreement that in another conversation with Blagojevich, after Blagojevich asked Respondent to develop a union based option, Respondent presented Blagojevich with an idea by which Blagojevich could become the national coordinator of an organization called "Change to Win," which was associated with a number of labor unions, including SEIU. (Id., p. 6.) Respondent suggested that Blagojevich could obtain the Change to Win position through SEIU Officials A and B, in exchange for Blagojevich agreeing to appoint Senate Candidate B the Senator. (Id.) Respondent explained the benefits of this plan to Blagojevich, which Respondent stated included the President's favorable view of SEIU during his administration, keeping Blagojevich politically viable, providing Blagojevich with union support and a paid position. (Id., pp.6-7)

As Respondent admits in the plea agreement, on November 7, 2008, Respondent participated in a conference call with Blagojevich and another person, Advisor A, in which the Change to Win idea was again discussed. (Id., p. 8) Respondent explained the idea to Advisor A at Blagojevich's request. (Id.)Respondent understood during the call that in his analysis of who to name to the Senate seat, Blagojevich was interested in obtaining money for himself and maintaining his own political viability. (Id.)

Respondent also admits in his plea agreement that after Senate Candidate B obtained a position with the White House, Blagojevich pressed Respondent to talk to an individual identified as Senate Candidate D about benefits to Blagojevich in exchange for the appointment to the seat which included Blagojevich's receipt of Candidate D's remaining campaign funds in exchange for the Senate seat. (Exh. 2, p.9) On November 12, 2008, Respondent met with Senate Candidate D. (Id., p.10) Respondent discussed with Candidate D, that individual's plans for his campaign funds that could not be converted to personal use. (Id., p. 10)

Respondent admits in the plea agreement that, in another conversation on December 4, 2008, Blagojevich told Respondent that through a third party, Senate Candidate A had offered to raise $1.5 million in campaign funds for Blagojevich in exchange for the Senate appointment. (Id., p.10) Although Respondent told Blagojevich that the offer to raise funds should not factor into his decision, it was clear to Respondent that a large part of Blagojevich's motivation for appointing Senate Candidate A to the Senate was the offer of campaign funds. Blagojevich had previously dismissed Senate Candidate A as a potential appointee, and Respondent believed that Blagojevich had changed course was considering Senate Candidate A because of the offer of money. (Id., pp. 10-11)